French EPR representative for companies based in Hong Kong
No establishment in France means you are the producer for French EPR, wherever your company is registered.
A company based in Hong Kong that sells to customers in France without an establishment there is the producer under French EPR. Since 10 July 2026 it must appoint an authorised representative established in France (article L. 541-10-9-1 of the Environmental Code), join an eco-organisme for each stream and hold one IDU per stream. Hong Kong's producer responsibility schemes cover Hong Kong only. EPR France Rep handles all of it: Standard costs €190 a year for one stream and Plus €990 a year for up to three, with a median saving of €1,071 a year in eco-contributions across our published clothing, footwear, electronics and furniture examples, with €0 setup. Eco-contributions are paid at the official rate, with 0% markup. Our website and written support are available in English, French, German, Spanish, Italian, Chinese and Turkish.
Légifrance
- Based in
- Hong Kong
- Typical sales channels
- Amazon.fr and FBA, Temu, AliExpress, TikTok Shop, own store, French importers
- Your home registration
- Hong Kong's producer responsibility schemes cover Hong Kong only
- Our fee
- Standard €190 a year for one stream; Plus €990 a year, with a median saving of €1,071 a year in eco-contributions across our published clothing, footwear, electronics and furniture examples
- Setup
- €0, no deposit
- IDU
- One per stream, typically a few days after you sign the mandate after the membership is filed
- Languages
- Website and written support in English, French, German, Spanish, Italian, Chinese and Turkish
Who is the producer in your setup?
Your own webshop
You sell directly to French consumers: you are the producer from the first parcel, and your IDU goes on your website. See French EPR for online stores. 
ADEME
Amazon.fr and other marketplaces
Every unit a marketplace delivers to a French customer for you is placed on the French market by you. One IDU per stream covers every platform. ADEME
Stock at a 3PL or Amazon warehouse
The warehouse stores and ships; it never buys your goods. Its parcels to French customers are your sales, and it does not make you established in France.
A French distributor buys and resells
The distributor takes title and places the goods on the French market: it is the producer for those goods.
French businesses use the goods
You are the producer. Professional streams apply, and professional packaging from 1 January 2027. ADEME
A French subsidiary sells for you
The subsidiary is the producer for its sales and needs no representative. Sales that bypass it still do. See French subsidiary.
Do we need it?
When does French EPR start for a company based in Hong Kong?
With the first product it places on the French market: the first Amazon.fr order delivered to a French customer, the first parcel from your own store to a French address, the first shipment to a French business that uses the goods. There is no minimum quantity, and free samples and giveaways count too. Where the goods are made or stored plays no part.
Is a French representative compulsory for a company based in Hong Kong?
Yes. Since 10 July 2026, article L. 541-10-9-1 of the Environmental Code requires every producer not established in France, inside or outside the EU, to appoint a representative established in France by written mandate, for every EPR stream. The representative is subrogated in your obligations: it holds your memberships, your IDUs and your declarations. You remain the producer, and the eco-contributions remain yours. Légifrance
Does our registration in Hong Kong cover France?
No. Hong Kong's producer responsibility schemes cover Hong Kong only. France keeps its own register and issues its own identifier, the IDU, for each stream. ADEME
Our Hong Kong company sells, our mainland factory makes. Which signs?
The Hong Kong company, if it holds the seller account and invoices French customers. The factory's registration does not cover the Hong Kong company's sales.
We have a French VAT number. Does that make us established in France?
No. French tax law itself treats companies with a French VAT number as foreign companies not established in France. You still need a French representative. See VAT number and establishment.
Our stock is at a fulfilment centre or 3PL in France. Does that make us established there?
No. A warehouse, a 3PL or an Amazon fulfilment centre is someone else's premises run by someone else's staff, not an establishment of your business. What French stock does mean is that its parcels to French customers are your sales, so you are the producer. See does a French warehouse make me established?
Amazon.fr, Cdiscount, TikTok Shop
Amazon.fr asks for our EPR number, or has deactivated listings. What now?
You need your own IDU for each stream your products fall under. We sign the mandate with you, join the eco-organismes in your name, and ADEME issues the IDUs, typically a few days after you sign the mandate. Once a valid IDU is entered in Account Health, reactivation typically follows within a few business days. See Amazon.fr asks for an EPR number. Sources (2)ADEMEADEME — all about the unique identifier (IDU)ADEMEADEME — which producers the EPR schemes cover
Do we need a separate IDU for each marketplace?
No. The IDU is issued to your company per stream, not per marketplace. The same identifier goes into Amazon.fr, Cdiscount, ManoMano, TikTok Shop, Zalando and your own website. What you need is one IDU per stream: a speaker with a built-in battery needs three (packaging, electrical equipment, batteries). See several IDUs. Sources (2)ADEMEADEME — Filière REP Batteries (BAT)ADEMEADEME — all about the unique identifier (IDU)
Must the IDU be in the name of the company that holds our seller account?
Yes. The IDU is issued to the legal entity that places the goods on the French market, and marketplaces check it against ADEME's public register. Register the company that holds the seller account and invoices French customers; an IDU in the name of a sister company or your factory will not match. Sources (2)ADEMEADEME — all about the unique identifier (IDU)ADEMEADEME — which producers the EPR schemes cover
Amazon or TikTok Shop pays the eco-contributions for us. Isn't that enough?
No. Pay on Behalf services only pay eco-contributions for what that platform sells for you. They give you no IDU, do not cover your own website or other marketplaces, and the platforms ask sellers for their own EPR numbers. See Amazon Pay on Behalf. ADEME
Who is the producer, and for what
We sell to a French distributor or importer. Who is the producer?
The company that first places the goods on the French market. If a French company buys your goods and resells them, it is the producer for those goods and you need nothing in France for that flow. If you sell directly to French consumers, or to French businesses that use the goods themselves, you are. The Incoterm (DDP, DAP, FOB) does not change this. See DDP, DAP and who the producer is.
We also sell to French businesses. What changes?
Products used by businesses can fall under professional streams, and professional packaging (EPRO) applies from 1 January 2027. Plus Pro, €990 a year, covers your consumer and business streams together, up to three.
Do our packaging labels need to change for France?
Household packaging sold in France must carry the Triman logo with sorting instructions (Info-tri), whatever its origin. Many brands add a French sticker or a France-specific print run. See Triman and the sorting label. Légifrance
Cost, documents and timing
What does it cost?
Standard costs €190 a year for one stream. Plus covers up to three streams: Plus €990 a year, with a median saving of €1,071 a year in eco-contributions across our published clothing, footwear, electronics and furniture examples. Setup is €0 and there is no deposit. Eco-contributions are paid to the eco-organismes at their published rates, with 0% markup. You see the full price on the pricing page and can order online the same day.
What details do you need from a company in Hong Kong?
Your company name and address and your Business Registration number. Then your product families, packaging, sales channels into France, and the signed mandate. See details for a French IDU. ADEME
How long until we have our IDUs?
Once the memberships are filed, the eco-organismes register you and ADEME issues one IDU per stream, typically a few days after you sign the mandate. Sources (2)ADEMEADEME — all about the unique identifier (IDU)ADEMEADEME — which producers the EPR schemes cover
How often do we declare, and who files?
Most streams declare once a year, for the previous year's sales, on each eco-organisme's own calendar; some ask for more frequent declarations above certain volumes. You send your sales figures; we prepare and file each declaration. ADEME
We already joined Citeo or another eco-organisme directly. Do we start again?
No. Your membership and your IDU stay valid. Since 10 July 2026 you need a representative on top: you appoint us and the membership runs under our mandate. See keeping an existing membership. Sources (2)LégifranceLégifrance — article L. 541-10-9-1 of the Environmental Code (full text)ADEMEADEME — all about the unique identifier (IDU)
What happens if we are not registered?
Marketplaces selling to French customers must either hold your IDU for each stream or pay the eco-contributions in your place (article L. 541-10-9), and they pass the cost on: Cdiscount adds 7.3% to its higher simplified scale, and some platforms block listings. Article L. 541-9-5 provides fines of up to €7,500 per unit or tonne for a company, a daily penalty of up to €20,000, and up to €30,000 for register and IDU failures. See penalties. Sources (2)LégifranceLégifrance — article L. 541-9-5 of the Environmental Code (sanctions)
Ministère de l'ÉcologieMinistère de l'Écologie — FAQ places de marché, article L. 541-10-9 (version du 1er août 2022)
What a business like yours pays in year one
Apparel brand shipping to France
- Streams
- Household packaging, textiles
- Plan
- Plus, €990 a year, €0 setup
- Example
- 2,000 women's T-shirts a year: €1,159.80 at basic rates, €64.60 with Plus
Saving in eco-contributions with Plus
€1,095.20
Electronics brand on Amazon.fr
- Streams
- Household packaging, electrical equipment, batteries
- Plan
- Plus, €990 a year, €0 setup
- Example
- 1,000 laptops a year: €5,410 at basic rates, €3,780 with Plus
Saving in eco-contributions with Plus
€1,630
Furniture or home brand selling online
- Streams
- Household packaging, furniture
- Plan
- Plus, €990 a year, €0 setup
- Example
- 800 padded armchairs (12 kg) a year: €3,616 at basic rates, €2,584 with Plus
Saving in eco-contributions with Plus
€1,032
Eco-contributions at the eco-organismes' published 2026 rates, before our fee. Packaging contributions and VAT not included. Calculate your saving with Plus →
The same products at other volumes
| Product | Units a year | Basic rate | With Plus | Saving with Plus |
|---|---|---|---|---|
| Women's T-shirts | 500 | €289.95 | €16.15 | €273.80 |
| Women's T-shirts | 2,000 | €1,159.80 | €64.60 | €1,095.20 |
| Women's T-shirts | 8,000 | €4,639.20 | €258.40 | €4,380.80 |
| Laptops | 250 | €1,352.50 | €945 | €407.50 |
| Laptops | 1,000 | €5,410 | €3,780 | €1,630 |
| Laptops | 4,000 | €21,640 | €15,120 | €6,520 |
| Padded armchairs (12 kg) | 200 | €904 | €646 | €258 |
| Padded armchairs (12 kg) | 800 | €3,616 | €2,584 | €1,032 |
| Padded armchairs (12 kg) | 3,200 | €14,464 | €10,336 | €4,128 |
The streams sellers like you trigger most
Household packaging & graphic paper
Any packaging reaching consumers, including e-commerce shipping boxes and filling, plus catalogues, leaflets and printed paper. One scheme, one IDU. The EU packaging regulation (PPWR) also applies — see our PPWR guide.
Learn more →Electrical & electronic equipment
Anything that runs on electricity or batteries, household and professional.
Learn more →Batteries
Portable, industrial, light-vehicle and vehicle batteries.
Learn more →Textiles, linen & shoes
Clothing, household linen and shoes sold to consumers.
Learn more →Furniture
Household and professional furniture, bedding and upholstery.
Learn more →Toys
Toys and games.
Learn more →What happens after you order
1. Order online
Choose your plan on the pricing page and pay by card. No quote to wait for.
2. Your client portal
You land in your portal: sign the mandate, add your company details and name your streams.
3. Memberships filed
We join the eco-organismes in your name, one per stream.
4. Your IDUs
ADEME issues one IDU per stream, typically a few days after you sign the mandate. You enter them in your marketplace accounts and on your website. Sources (2)ADEMEADEME — all about the unique identifier (IDU)ADEMEADEME — which producers the EPR schemes cover
5. Declarations
You send your sales figures; we prepare and file each declaration.
Who is the producer, by set-up
| Set-up | Producer for French EPR |
|---|---|
| You sell to French customers and ship from abroad | You Légifrance |
| Your stock is in a French or EU warehouse, sold in your name | You |
| A French distributor imports and resells | The distributor |
| A marketplace buys and resells as retailer | The marketplace |
| A retailer sells your goods under its own brand | The retailer |
Your first year in France
| When | What | Source |
|---|---|---|
| Before the first French sale | Representative appointed, IDU per stream, IDUs in every marketplace ADEME | Sources (2)LégifranceLégifrance — article L. 541-10-9-1 of the Environmental Code (full text)ADEMEADEME — all about the unique identifier (IDU) |
| On every household pack | Triman and Info-tri | French Ministry of Ecologica |
| From 1 January 2027 | Professional packaging scheme, if you sell to businesses | ADEME |
| Early the following year | Declaration of the previous year's French sales |  Citeo |
| All year | Eco-contributions at published rates, no markup |  Léko |
Sanctions if nothing is filed
| Failure | Sanction | Source |
|---|---|---|
| Not meeting EPR duties after formal notice | Up to €1,500 (individual) or €7,500 (company) per unit or tonne concerned | Légifrance |
| Still not complying | Daily penalty up to €20,000 | Légifrance |
| Register and IDU failures | Fine up to €30,000 | Légifrance |
| No IDU on a marketplace | The platform blocks the listing or pays in your place | Ministère de l'Écologie |
Get started today
Sign your mandate online: we register you with the eco-organismes and obtain your IDU. Official rates, 0% markup. Sources (2)ADEMEADEME — all about the unique identifier (IDU)ADEMEADEME — which producers the EPR schemes cover